{"operation":"document","citation":"01-0130","title":"ENPRO Services Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-06-26","effective_on":null,"summary":"01-0130 response to ENPRO Services Inc. concerning 172.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0130.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0130.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0130","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010130.pdf","body":"<<<PAGE 1>>>\n\nS. Departme\nTransportatic\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nJUN 2 6 2001\nMs. Alice M. Morse\nRef. No: 01-0130\nENPRO Services Inc.\n12 Mulliken Way\nNewburyport, MA 01950\nDear Ms. Morse:\nThis is in response to your May 11, 2001 letter regarding the classification and proper shipping name\nfor a waste material containing petroleum oil and water and contaminated with debris (soil, PPE,\nabsorbents, speedy dry, etc.) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-\n180).\nYou state that during a routine stop by the Massachusetts State Police, your company was issued a\nwritten warning for an improper shipping name on a uniform hazardous waste manifest. The shipping\nname on the manifest was \"State Regulated Oil Waste.\" Specifically, you asked if the shipping name\n\"State Regulated Oil Waste\" is an acceptable proper shipping name to describe this material.\nUnder the HMR, a waste that is subject to the Uniform Hazardous Waste Manifest (UHWM)\nRequirements of the U. S. Environmental Protection Agency specified in 40 CFR part 262 is regulated\nfor purposes of transportation as a \"hazardous waste.\" A waste that does not require completion of a\nUHWM is not considered a \"hazardous waste\" for purposes of transportation and is not subject to the\nrequirements of the HMR unless it meets the definition of a hazardous material under the HMR. Thus,\na State regulated waste that does not require completion of a UHWM and is not a hazardous material\nas defined in the HMR is not subject to the regulations under the HMR. Such a material may be\ndescribed using the shipping name, \"State Regulated Oil Waste.\" However its description on the\nshipping paper or manifest may not include a hazard class or identification number specified in the\n§ 172.101 Hazardous Materials Table (See § 172.202(e)).\nI hope this satisfies your inquiry.\nIf we can be of further assistance, please contact us.\nSincerely\nJohn A. Gale\nTransportation Regulations Specialist\nOffice of Hazardous Materials Standards\n172.101\n010130\n\n<<<PAGE 2>>>\n\nEngrum\n3112.101\nENPRO\nProper Shipping Name.\n01-0130\nMay 11, 2001\nMr. Ed Mazzullo, Director\nOffice of Hazardous Materials\n400 7th Street, SW\nWashington, D.C. 20590-0001\nReference:\nClarification on the Regulations\nDear Mr. Mazzullo,\nI am writing to you in an attempt to get clarification on the correct way to\ncomplete the proper shipping name on a hazardous waste manifest for\npetroleum oil contaminated with water and petroleum oil products\ncontaminated debris (soil, PPE, absorbents, speedy dry, etc).\nENPRO Services, Inc. is a licensed hazardous materials transportation\nissued a written warning for an improper shipping name on a uniform\ncompany. During a routine stop by the Massachusetts State Police we were\nState Regulated Oil Waste.\nhazardous waste manifest. The shipping name on the manifest was listed as\nWhen I called the Department of Transportation hotline at (800) 467-4922, I\nwas informed that State Regulated Oil Waste was indeed a proper shipping\nname of these materials. The hotline operator informed me at this time there is\nno written section in the regulations stating this for a fact.\nCould you please provide a written statement, confirming the above information\nthat was provided to me verbally by the hotline operator. Please do not hesitate\nto call me should your require additional information.\nSincerely,\nENPRO Service, Inc.\nAlic Morse\nAlice M. Morse\nHazardous Waste Coordinator\nENPRO Services, Inc.\n12 Mulliken Way, Newburyport, MA 01950\n(800) 966-1102 - 24 Hours FAX (978) 465-2050\n(888) 367-6660 - 24 Hours FAX (207) 773-6693\n44 Rigby Road, South Portland, ME 04106","truncated":false,"body_characters":3691}